Third Party Vendor Code of Conduct
Third Party Vendor Code of Conduct
Third Party Vendor Code of Conduct
March 2020
Introduction 3
Report Concerns 9
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Third Party/Vendor Code of Conduct
Introduction
IHS Markit’s reputation as a leader in information, analytics, and solutions is built on a longstanding
commitment to, and foundation of, integrity, honesty, and ethical conduct. IHS Markit’s success
depends not only on its own conduct, but also on the actions of those with whom IHS Markit does
business. For that reason, we aspire to work only with third parties who share our passion for doing
business with integrity and reflect the same high ethical standards.
This Third Party/Vendor Code of Conduct (“Code”) articulates the legal and ethical conduct we expect
from suppliers, vendors, distributors, channel partners, agents, contractors, and all other third parties
with whom we work (“Third Parties”). IHS Markit recognizes that its Third Parties operate in different
legal and cultural environments throughout the world. Nevertheless, IHS Markit requires that its Third
Parties comply with the fundamental legal and ethical principles described in this Code and take all
reasonable steps to ensure compliance with applicable laws and regulations when conducting
business with or on behalf of IHS Markit. Failure to do so may result in the termination of our
relationship.
We require Third Parties to take reasonable steps to ensure that this Code is communicated
throughout their organizations and made available to their employees and subcontractors who work
on IHS Markit business. This Code must be understood and complied with when conducting business
with or on behalf of IHS Markit, in conjunction with the standards and principles in the IHS Markit
Business Code of Conduct, the provisions of any contract between the Third Party and IHS Markit,
and the Third Party’s own comparable standards of ethical business conduct.
Anti-Corruption
IHS Markit is committed to conducting its business free from extortion, bribery, and all unlawful,
unethical, or fraudulent activity, regardless of differing local business customs or traditions. We do not
tolerate bribery in any form, whether public or private. When conducting business with or on behalf of
IHS Markit, Third Parties must:
• Act ethically and transparently in all business dealings.
• Never offer, give, promise, request, accept, or authorize any bribe, gift, fee, reward,
advantage, or anything else of value, directly or indirectly, to any person or entity to obtain or
retain business or to improperly influence any action or decision.
• Comply with all applicable local and international anti-corruption laws, regulations, treaties,
and conventions, including the US Foreign Corrupt Practices Act and the UK Bribery Act.
• Never make facilitation payments, whether directly or indirectly.
• Ensure all subcontractors, referral parties, and affiliates used in connection with IHS Markit
business adhere to these standards and have not engaged in, and are not likely to engage
in, improper or illegal conduct.
All Third Parties doing business in connection with IHS Markit business in Japan must comply with
IHS Markit’s Policy Against Anti-Social Forces, available at https://ihsmarkit.com/legal/policy-against-
anti-social-forces.html.
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Third Party/Vendor Code of Conduct
As appropriate, IHS Markit may require Third Parties to submit an annual review of their continuing
compliance with anti-corruption laws. IHS Markit may also require Third Parties to complete training
courses and annual compliance certifications as part of the company’s corporate ethics and
compliance program.
Trade Practices
IHS Markit requires its Third Parties to comply with all applicable trade laws and regulations, including
obtaining proper export authorization, establishing eligibility of export recipients, and securing all
required licenses and documentation.
Due to the extensive presence of US touchpoints throughout our organization, Third Parties must
always also comply with US trade regulations, regardless of where in the world they are operating,
when conducting IHS Markit business. This means that Third Parties may not conduct IHS Markit
business with destinations subject to comprehensive embargoes (as of the date of this policy, this
includes Cuba, Iran, North Korea, Syria, and the Crimea Region of Ukraine) or with persons or
entities identified on any restricted party screening lists (including the US Treasury Department Office
of Foreign Assets Control Specially Designated Nationals List and the US Commerce Department
Bureau of Industry and Security Entity List). In addition, Third Parties may not agree to participate in
boycotts that are not sanctioned by the US government (e.g., the Arab League boycott of Israel) in
connection with IHS Markit business.
Insider Trading
While working with or for IHS Markit, Third Parties may become aware of non-public information
about IHS Markit, other companies, or the market in general. Using non-public information to trade in
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Third Party/Vendor Code of Conduct
securities, or providing a family member, friend, or any other person with a "tip" about non-public
information, is a violation of this Code and, if the information is deemed "material," potentially illegal.
Third Parties shall ensure that non-public information entrusted to them by IHS Markit is not used for
the benefit of the Third Party or any other person or entity.
Anti-Money Laundering
Third Parties must comply with anti-money laundering and anti-terrorism regulations and take the
necessary steps to ensure that IHS Markit business is conducted only with reputable customers that
are financed only from legitimate sources.
Privacy
IHS Markit expects its Third Parties to protect the personal information that they access, collect,
receive, process, use, or retain on behalf of IHS Markit. Third Parties must always comply with
applicable laws and regulations and must implement policies and controls to ensure that applicable
privacy rights of individuals are respected. Third Parties should recognize that unauthorized use or
disclosure of such information may have personal, legal, reputational, and financial consequences for
the Third Party, IHS Markit, and the individuals whose information is implicated.
Any Third Party that accesses, collects, processes, uses, or retains personal information at IHS
Markit’s request or on IHS Markit’s behalf may be required to agree to certain contractual obligations
to ensure compliance with IHS Markit’s standards regarding the protection of personal information.
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Third Party/Vendor Code of Conduct
Third Parties must obtain pre-approval from Corporate Compliance for any business courtesies
offered, given, or received in connection with IHS Markit business that:
• Involve Government Personnel1; or
• Exceed $200 per person, per instance
Pre-approval can be requested using the IHS Markit Business Courtesies Form, available at
https://ihsmarkitbusinesscourtesies.ethicspoint.com/.
1 “Government personnel” includes any elected or appointed public official in any branch of government
(executive, legislative, judicial); any employee, agent, or representative of any government agency; any
employee, agent, or representative of any company or organization owned or controlled, in whole or in part, by a
government agency; any candidate for political office; ambassadors and representatives of foreign governments;
honorary officials, such as royal family members; union officials; judges, legislators, and their staff members; and
representatives and employees of political parties and public international organizations, such as the
International Red Cross, United Nations, World Bank, NATO, and FIFA. Government personnel also include
immediate family members of any of the individuals who fit this definition of “government personnel.”
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Third Party/Vendor Code of Conduct
In accordance with local law, and as it pertains to the services for which they are engaged, Third
Parties may also be required to follow certain information security requirements and undergo
associated training.
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Third Party/Vendor Code of Conduct
not infringe upon the intellectual property rights of other companies or violate any terms and
conditions established by contract with IHS Markit.
Proprietary information is any information that is owned by IHS Markit, including information in IHS
Markit databases and confidential or publicly available information, regardless of whether such
information is subject to copyright, patent, or other intellectual property right protections. Examples of
proprietary information include IHS Markit publications, technical or financial information relating to
current or future products, services, or research, business or marketing plans or protection, personnel
information, earnings and other financial data, and software.
Third Parties must return all confidential and proprietary information in their possession to IHS Markit
when the contractual relationship between IHS Markit and the Third Party has terminated, unless
otherwise specified by contract. The obligation to protect IHS Markit information continues even after
any business relationship between IHS Markit and the Third Party ends.
Environmental Responsibility
IHS Markit is committed to environmental stewardship and expects Third Parties to maintain process
that help reduce waste, improve resource efficiency, and mitigate the effects of climate change. IHS
Markit expects Third Parties to safeguard the health and safety of the public and minimize adverse
operational effects to communities, the environment, and natural resources when conducting
business with or on behalf of IHS Markit. This includes the expectation that Third Parties employ
practices that optimize waste and energy usage by taking steps to modify production, maintenance,
and facility processes that improve resource efficiency and reduction.
IHS Markit expects all Third Parties to obtain, maintain, and keep current all required environmental
permits (for example, discharge monitoring) and registrations, and to follow all operational and
reporting requirements.
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Third Party/Vendor Code of Conduct
Report Concerns
Subject to local laws and any legal restrictions, IHS Markit requires that Third Parties report any
violation of this Code or applicable law in connection with IHS Markit business to the IHS Markit
Compliance Hotline at www.ihsmarkithotline.ethicspoint.com. The Hotline is available in a variety of
different languages, 24 hours a day, 7 days a week. When allowed by local law, calls to the IHS
Markit Compliance Hotline may be placed anonymously. IHS Markit prohibits retaliation for good faith
reports of suspected misconduct. For further information, please see IHS Markit’s Compliance Hotline
and Reporting Misconduct Policy, accessible at https://investor.ihsmarkit.com/corporate-governance.
Legal Notice: IHS Markit reserves the right to revise this Third Party/Vendor Code of Conduct (“Code of Conduct”) at any time.
The IHS Markit Third Party/Vendor Code of Conduct is not a contract. It does not confer rights on anyone, including without
limitation, Third Parties or their agents or employees, and imposes no obligations on IHS Markit. If an inconsistency arises
between this Code of Conduct and the provisions of any written agreement between IHS Markit and Third Party, the terms of
the written agreement prevail except to the extent they are contrary to law.
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